Select Committee on Education and Skills Minutes of Evidence



  Thank you for the opportunity to have sight of the draft "Guide for Learning Providers" and the opportunity to make some observations on the new regulations. My colleagues and I have studied the document in some detail and, bearing in mind the shortness of time to make major changes, have put forward four substantive points that we feel will strengthen the ILA process without penalising the legitimate providers. The points are as follows:

1.  Quality Assurance for Providers

  We have believed from the beginning of the ILA scheme that there should be some simple, but effective, method of ensuring that providers meet minimum quality standards. This has been seen as difficult to achieve by DfES because of the large numbers of specialist providers operating on a very small scale.

  However, most of the changes brought in recently and in this revised Guide are needed solely because of the activities of businesses that have little connection with training delivery, other than a sense of opportunism. There is, we believe, a quick and effective remedy.

  Most of the providers who would be negatively affected claim discounts at 20 per cent or, if claiming 80 per cent, will mainly be training in Mathematics. If quality barriers were introduced only to IT provision—at 80 per cent—very few legitimate providers would be affected, whilst the minority of dubious providers causing such difficulty over recent months would be taken out of the system overnight.

  The system would be very simple to operate and would rely on the prior acceptance of the provider into schemes operated by Government departments or independent agencies that already demand minimum quality levels from trainers. Examples of this would include (amongst others):

    —  Employment Service Approved Provider status

    —  LearnDirect Centre

    —  ECDL Testing Centre

    —  UK OnLine Centre

    —  OCR Centre

  In the very rare examples that a legitimate provider did not have any such recognition, they could very easily and inexpensively seek approval form one of the above or, perhaps, get a written reference from their local Learning & Skills Council. The street traders, with no training background would be unable to comply.

2.  Payment of Personal Contribution

  We fully understand the desire to tighten up in this area; although we are also confident that acceptance of Item 1 above would lessen the need to do so by removing the root cause of the problem. However, we feel that there is one new rule that will actually lead to greater drop-out of individuals before starting their training.

  In the Guide you state that: "the personal contribution....should be made after the individual has become a member of the national framework of Individual Learning Accounts, and on or after the date they enrol on their course". This is clearly intended to prevent street traders and others collecting money without ever intending to provide training. However, it will have a significant negative effect on legitimate providers.

  The time period between the individual recognising the opportunity afforded by an Individual Learning Account and the start of training is crucial in maintaining motivation. Our own experience over the past twelve months has shown clearly that the longer the delay, the greater the drop-out. By taking a deposit from the individual, the drop-out rate is reduced significantly and the motivation is maintained. Provided the deposit taken is properly receipted and is refundable under clearly defined terms, we can see no objection to this being done by a legitimate provider.

3.  Start Certificates

  We welcome the switch from Enrolment Forms to Start Certificates as a way of tightening up on fraudulent or inappropriate use of the system. However, we see a difficulty in the insistence (as we interpret the wording) that the provider must claim the funding within seven days of the individual signing the form.

  The difficulty will arise in the distance learning sector, where the provider will be reliant on the individual's prompt posting of the document and the reliability of the postal service. Experience shows that seven days is too narrow a window; we would strongly urge you to extend this period to 14, or even 21 days.

  We have a second potential problem with the use of Start Certificates for distance learners. The Enrolment forms come in books, rather than individual loose forms. Clearly, the book cannot be sent to the student, nor should forms be detached from the book. We suggest, therefore, that the certificates are supplied as individual, numbered, duplicate sheets.

4.  Deferred Payments

  We feel the DfES would be well advised to introduce a rule on deferred payments. It is absolutely right that individuals should be offered time to pay their contributions; however, a loophole exists whereby the individual could, for example, be invited to pay a few pence per month over many years. This diminishes the value and purpose of the personal contribution and is sure (to continue) to be looked at as "free" training.

  In summary, we believe that the fundamental problem with Individual Learning Accounts lies with the misuse of the system by businesses with little connection with training, that are exploiting loopholes in the rules. This new Guide will go some way towards closing these loopholes, though at a cost to legitimate providers.

  We strongly urge you to look at our first substantive point on quality: do that and the rest will fall into place. We look forward to meeting you shortly to discuss this and other matters. We would be very happy to host the meeting at Wetherby, or in any of our training centres if that would be helpful to you.

October 2001

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